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Last Modified: 29 October 2007

Croydon Gateway Public Inquiry - Planning Application Inquiry Documents

This page contains documents relating to the Planning Application Inquiry.

Parties:  Arrowcroft
London Borough of Croydon
Croydon Gateway Limited Partnership
Interested Parties
And:   Documents Presented at Inquiry

ARROWCROFT LTD DOCUMENTS

Witness 1:Mr Murray Beynon (Arena Design and Operation)
1/Arrow/1/1 Proof of Evidence [1,913 KB]
1/Arrow/1/2 Review of Stanhope’s Croydon Gateway Northern Site Opportunities Study, 6 September 2007 [26 KB]
1/Arrow/1/3 Summary Proof of Evidence [208 KB]
1/Arrow/1/4 Statement of Clarification [68 KB]
Witness 2: Mr Michael Aukett (Design Concept and Proposal)
1/Arrow/2/1 Proof of Evidence, with DVD [38 KB]
1/Arrow/2/2 Michael Aukett Architects Limited Brochure
1/Arrow/2/3 Rebuttal Proof of Evidence in response to Professor Robert Tavernor [25 KB]
1/Arrow/2/4 Appendices to Rebuttal Proof of Evidence in response to Professor Robert Tavernor [11,398 KB]
1/Arrow/2/5 Appendix G to Rebuttal Proof of Evidence in response to Professor Robert Tavernor
1/Arrow/2/6 Responses arising from Proofs of Evidence
1/Arrow/2/7 Clarification of business relationship with other parties representing the Applicant
1/Arrow/2/8 Clarification of the brief concerning the Warehouse Theatre, letter of 23 October 2007
1/Arrow/2/9 Revised drawings SK765 and SK767, 23 October 2007
1/Arrow/2/10 Illustrative plans to show distribution & size of affordable residential units (Drawings SK800 – SK803 inc and SK760)
Witness 3: Mr Nicholas Bridges (Design Evaluation)
1/Arrow/3/1 Proof of Evidence [126 KB]
1/Arrow/3/2 Appendices to Proof of Evidence [17,752 KB]
1/Arrow/3/3 Summary Proof of Evidence [73 KB]
1/Arrow/3/4 Rebuttal Proof of Evidence in response to Professor Robert Tavernor & Mr David Williams [5,459 KB]
1/Arrow/3/5 Appendices to Rebuttal Proof of Evidence in response to Professor Robert Tavernor & Mr David Williams
1/Arrow/3/6 Key points of evidence
1/Arrow/3/7 Cumulative Effect plan number 013 Rev A, with the Dingwall Road site, Quest House and St. James’s site added
1/Arrow/3/8 Note on levels with drawing
Witness 4: Mr Graeme Tulley (Planning Policy & Planning Issues)
1/Arrow/4/1 Proof of Evidence [215 KB]
1/Arrow/4/2 Appendices to Proof of Evidence [167 KB]
1/Arrow/4/3 Rebuttal Proof of Evidence in response to Mr Alan Simmonds [74 KB]
1/Arrow/4/4 Summary Proof of Evidence [34 KB]
1/Arrow/4/5 Letter from Mr Andy Graham of One Brandy Group dated 14 September 2007 expressing views on the Rebuttal Proof of Mr William Hill
1/Arrow/4/6 E-mail of 1-9-07 to the Greater London Authority and e-mail response of 4-9-07
1/Arrow/4/7 Evidence in Chief – Key Points
Witness 5: Ms Bridget Rosewell (Business Case for Arena)
1/Arrow/5/1 Proof of Evidence [346 KB]
1/Arrow/5/2 Appendices to Proof of Evidence [492 KB]
1/Arrow/5/3 Rebuttal Proof of Evidence in response to Mr Stephen Lucas, Ms Yael Coifman & Mr Stephen Clarke [179 KB]
1/Arrow/5/4 Appendices to Rebuttal Proof of Evidence in response to Mr Stephen Lucas, Ms Yael Coifman & Mr Stephen Clarke [4,205 KB]
1/Arrow/5/5 Summary Proof of Evidence [77 KB]
1/Arrow/5/6 Response to the Rebuttal of Mr Stephen Lucas
1/Arrow/5/7 Letter from Mr Nick Massey of Octagon expressing support for proposals
1/Arrow/5/8 Evidence in Chief – Key Points
1/Arrow/5/9 Evidence in Chief – Key Flaws in the CGLP Approach
1/Arrow/5/10 Credentials
1/Arrow/5/11 Revised section 8.2 of Proof of Evidence following discussions with Mr Stephen Lucas
1/Arrow/5/12 Letter of support from Mr Brian Kabatznick of AEG Facilities Europe
1/Arrow/5/13 E-mail dated 26 September 2007 from Ms Jill Bensley, JP research Company clarifying report appended to Proof of Evidence
1/Arrow/5/14 Volterra note on Corporation Tax
1/Arrow/5/15 Letter from Mr John Craig, The Brit Trust, dated 17 October 2007
1/Arrow/5/16 Response to question Can Croydon Resident Afford to Visit the Arena?
1/Arrow/5/17 Volterra note addressing Mr Stephen Clarke’s Rebuttal Appendices B – D
1/Arrow/5/18 E-mail of Ms Clare Mirfin on behalf of CGLP, dated 6 November 2007, enclosing the operational cash analysis table and comparison table with e-mail of Mr Paul Grace on behalf of Arrowcroft, dated 9 November 2007 (also filed as 1/Arrow/5/18)
1/Arrow/5/19 Letter dated 8 November 2007 from Mr Mark Anderson, on behalf of the Royal Bank of Scotland, concerning the issuance of indicative terms
1/Arrow/5/20 Letter dated 9 November 2007 from Mr David Field, on behalf of Nestlé UK Ltd, to Mr P Nally of Stadivarios Croydon Ltd
1/Arrow/5/21 Response to documents 1/CGLP/6/8, 1/CGLP/6/10 and 1/CGLP/6/11
1/Arrow/5/22 Response to documents 2/CGLP/4/10 relating to Mr Stephen Clarke’s Rebuttal Appendices B – D and 2/CGLP/4/11 relating to Capital Allowances
Witness 6: Mr Andrew Roberts/Mr Andreas Markides (Highways & Transportation)
1/Arrow/6/1 Proof of Evidence [108 KB]
1/Arrow/6/2 Appendices to Proof of Evidence [11,038 KB]
1/Arrow/6/3 Not Used
1/Arrow/6/4 Rebuttal Proof of Evidence in response to Mr David Bird [139 KB]
1/Arrow/6/5 Appendices and Figures to Rebuttal Proof of Evidence in response to Mr David Bird [5,432 KB]
1/Arrow/6/6 Rebuttal Proof of Evidence of Mr Andreas Markides [603 KB]
1/Arrow/6/7
Appendices to Rebuttal Proof of Evidence of Mr Andreas Markides: - Appendix 1 (Safety Audit) [237 KB]
- Appendix 2 (JMP response) [10 KB]
- Appendix 3 (Servicing) [4,136 KB]
- Appendix 4 (TRICS Output) [86 KB]
- Appendix 5 (Telephone Surveys of A3 Restaurants) [10 KB]
- Appendix 6 (Data on Moving House) [10 KB]
- Appendix 7 (Arena Servicing) [16 KB]
- Appendix 8 (Tree Planting) [81 KB]
- Appendix 9 (Manual for Streets Extract) [38 KB]
- Appendix 10 (Pedestrian Flows) [2,883 KB]
- Appendix 11 (Coaches) [1,165 KB]
- Appendix 12 (Trip Generation) [462 KB]
- Appendix 13 (TRANSYT) [7,414 KB]
 - Appendix 14 (PTAL Map of Brent and TRICS Output for Alperton ) [309 KB]
- Appendix 15 (Parking Accumulation) [20 KB]
- Appendix 16 (Route Map) [187 KB]
1/Arrow/6/8 Service Area Amendment
1/Arrow/6/9 Aide Memoire for Evidence
1/Arrow/6/10 Technical Note – Taxi Analysis, 1 November 2007
1/Arrow/6/11 Technical Note – Transyt Results, 30 October 2007
1/Arrow/6/12 Technical Note – Cycle and Car Parking
1/Arrow/6/13 Technical Note- with drawings and figures – Trip Generation & Transyt; Lansdowne Road/Dingwall Road Signalised Junction; Food Store Home Deliveries; Survey Data; Service Area 1; Sydenham Road; and Tramtrack – Dingwall Road
1/Arrow/6/14 Technical Note – Impact of Traffic flows along Lansdowne Road – update, 9 November 2007
1/Arrow/6/15 Summary of oral submissions in relation to the Stopping Up Order
Witness 7: Mr George Venning (Affordable Housing)
1/Arrow/7/1 Rebuttal Proof of Evidence in response to Ms Claire Dickinson [35 KB]
1/Arrow/7/2 Summary of case
1/Arrow/7/3 Letter dated 25 September 2007 from Ms Tina Jordan, Housing Corporation, to the London Borough of Croydon
1/Arrow/7/4 Letter dated 24 September 2007 from Ms Susan May, Affinity Sutton Group Ltd, to Mr George Venning, Levvel
1/Arrow/7/5 Note on affordability, 25 September 2007
Witness 8: Mr Andrew Pepler (Retail)
1/Arrow/8/1 Rebuttal Proof of Evidence in response to Mr Alan Simmonds [87 KB]
1/Arrow/8/2 Appendices to Rebuttal Proof of Evidence in response to Mr Alan Simmonds [368 KB]
1/Arrow/8/3 Summary of Case – retail need & retail impact matters
1/Arrow/8/4 Note on capacity for additional convenience goods floorspace in Croydon
1/Arrow/8/5 Note clarifying the basis on which the household survey was produced

LONDON BOROUGH OF CROYDON

Witness 1: Mr Hugh Bullock (Planning Policy & Planning Issues)
1/LBC/1/1 Proof of Evidence with Appendix [164 KB]
1/LBC/1/2 Not Used
1/LBC/1/3 Rebuttal Proof of Evidence [62 KB]
1/LBC/1/4 Appendices to Supplementary Proof of Evidence [90 KB]
1/LBC/1/5 Summary Proof of Evidence [66 KB]
1/LBC/1/6 Errata to Proof of Evidence

CROYDON GATEWAY LIMITED PARTNERSHIP

General Documents:
1/CGLP/0/1 Waterman Environmental Review with Appendices – August 2007 [138 KB]
1/CGLP/0/2 Application for Partial Award of Costs
Witness 1: Professor Robert Tavernor (Townscape)
1/CGLP/1/1 Proof of Evidence [171 KB]
1/CGLP/1/2 Appendices to Proof of Evidence [4,495 KB]
1/CGLP/1/3 Rebuttal Proof of Evidence in response to Mr Murray Beynon, Mr Michael Aukett, Mr Nicholas Bridges and Mr Hugh Bullock [129 KB]
1/CGLP/1/4 Summary Proof of Evidence [68 KB]
1/CGLP/1/5 Review of Michael Aukett drawings
Witness 2: Mr David Bird (Transport)
1/CGLP/2/1 Proof of Evidence [209 KB]
1/CGLP/2/2 Appendices to Proof of Evidence [3,021 KB]
1/CGLP/2/3 Position Statement on evidence presented by Mr Andrew Roberts [25 KB]
1/CGLP/2/4 Rebuttal Proof of Evidence with Appendices in response to Mr Andrew Roberts [364 KB]
1/CGLP/2/5 Extracts from drawings SK 765H (Ground Floor Level) and SK 767F (Plaza Level)
1/CGLP/2/6 All accidents – 1 January 2004 to 312 March 2006 – East Croydon area
1/CGLP/2/7 Accident Review – Technical Note of accidents at the George Street/Dingwall Road junction, Mott Macdonald, January 2006
1/CGLP/2/8 Savell Bird & Axon Drawings 111/69D/AR/N1 to 111/69D/AR/N7 inc, 26 October 2007, regarding vehicle manoeuvres
1/CGLP/2/9 Extract from Transport for London – London Cycling Design Standards
1/CGLP/2/10 Main points of Evidence in Chief
1/CGLP/2/11 Pedestrian Flows at Crossing Points
1/CGLP/2/12 Signal surveys
1/CGLP/2/13 Tramtrack proposal for extension to Tramlink
1/CGLP/2/14 Savell Bird & Axon Drawings 11169D/AR/Q1 & 11169D/AR/Q4, 6 November 2007 regarding left turn manoeuvre
1/CGLP/2/15 Distances to Lansdowne Road entrance to Arena
1/CGLP/2/16 Savell Bird & Axon Drawings 11169D/AR/01 & 11169D/AR/02, 5 November 2007 regarding vehicle manoeuvres
Witness 3: Ms Claire Dickinson (Affordable Housing)
1/CGLP/3/1 Proof of Evidence [1,401 KB]
1/CGLP/3/2 Appendices to Proof of Evidence [63 KB]
1/CGLP/3/3 Rebuttal Proof of Evidence in response to Appendices of Mr Graeme Tulley [178 KB]
1/CGLP/3/4 Summary Proof of Evidence [216 KB]
1/CGLP/3/5 Appendix 4 (Schedule of Intermediate Units) and Appendix 5 (Affordability of Intermediate Units) to Proof of Evidence
1/CGLP/3/6 Appendix 6 to Proof of Evidence - Letter from Mr Dick Mortimer, Family Mosaic, dated 27 September 2007
1/CGLP/3/7 Appendix 7 to Proof of Evidence - CGLP Progress Update: Affordable Housing, 3 October 2007
Witness 4: Mr David Wiliams (Offices & Regeneration)
1/CGLP/4/1 Proof of Evidence [88 KB]
1/CGLP/4/2 Appendices to Proof of Evidence [441 KB]
1/CGLP/4/3 Rebuttal Proof of Evidence in response to Ms Bridget Rosewell, Mr Hugh Bullock, Mr Kevin Murray & Mr Graeme Tulley [22 KB]
1/CGLP/4/4 Appendices to Rebuttal Proof of Evidence in response to Ms Bridget Rosewell, Mr Hugh Bullock, Mr Kevin Murray & Mr Graeme Tulley [108 KB]
1/CGLP/4/5 Summary Proof of Evidence [100 KB]
1/CGLP/4/6 Office Development Schedule: London Borough of Croydon
1/CGLP/4/7 Croydon Gateway Overall Master Programme
1/CGLP/4/8 Appendix 4: Chart of CGLP Market take up September 2007
1/CGLP/4/9 Response to PACEC Review
1/CGLP/4/10 Additional note on office development in London
1/CGLP/4/11 Office (Use Class B1) Floorspace
1/CGLP/4/12 Responses to Mr Richard Harding’s comments on PACEC (document 1/72) and Average size of speculative office developments (document 1/74), 1 November 2007
1/CGLP/4/13 Response to Gerald Eve comments on PACEC (document 1/75), 1 November 2007
1/CGLP/4/14 Response to Mr Andrew Goodwin’s note on maximum office supply (2/LBC/Arrow/8/9)
1/CGLP/4/15 Note on Cardinal Place
Witness 5: Mr Mark Whitfield (evidence presented at CPO Inquiry, Witness 2)
1/CGLP/5/1 Proof of Evidence (see 2/CGLP/2/1)
1/CGLP/5/2 Appendices to Proof of Evidence (see 2/CGLP/2/2)
1/CGLP/5/3 Summary Proof of Evidence (see 2/CGLP/2/5)
Witness 6: Ms Yael Coifman (Arena Expert)
1/CGLP/6/1 Proof of Evidence [421 KB]
1/CGLP/6/2 Appendices to Proof of Evidence [301 KB]
1/CGLP/6/3 Rebuttal Proof of Evidence in response to Mr Murray Benyon & Ms Bridget Rosewell [116 KB]
1/CGLP/6/4 Summary Proof of Evidence [36 KB]
1/CGLP/6/5 Letter from Roger Black Developments dated 28 September 2007
1/CGLP/6/6 Letter from Mr David Campbell, AEG Europe, received 28 September 2007
1/CGLP/6/7 Commission Proposal of Economics Research Associates (ERA) to Stanhope plc
1/CGLP/6/8 E-mail of Ms Clare Mirfin on behalf of CGLP, dated 6 November 2007, enclosing the operational cash analysis table and comparison table with e-mail of Mr Paul Grace on behalf of Arrowcroft, dated 9 November 2007 (also filed as 1/Arrow/5/18)
1/CGLP/6/9 Catchment overlaps between the planned Brighton Arena and the London regional market
1/CGLP/6/10 Additional Sensitivities on the Arena Business Plan
1/CGLP/6/11 Map showing the relative locations of the NEC and NIA arenas
Witness 7: Mr Stephen Clarke (evidence presented at CPO Inquiry, Witness 4)
1/CGLP/7/1 Proof of Evidence (see 2/CGLP/4/1)
1/CGLP/7/2 Appendices to Proof of Evidence (see 2/CGLP/4/2)
1/CGLP/7/3 Rebuttal Proof of Evidence in response to Mr Alan Jones, Ms Bridget Rosewell & Mr Andrew Goodwin (see 2/CGLP/4/3)
1/CGLP/7/4 Appendices to Rebuttal Proof of Evidence in response to Mr Alan Jones, Ms Bridget Rosewell & Mr Andrew Goodwin (see 2/CGLP/4/4)
1/CGLP/7/5 Summary Proof of Evidence (see 2/CGLP/4/5)
Witness 8: Mr Stephen Lucas (evidence presented at CPO Inquiry, Witness 5)
1/CGLP/8/1 Proof of Evidence (see 2/CGLP/5/1)
1/CGLP/8/2 Appendices to Proof of Evidence (see 2/CGLP/5/2)
1/CGLP/8/3 Rebuttal Proof of Evidence in response to Ms Bridget Rosewell              (see 2/CGLP/5/3)
1/CGLP/8/4 Summary Proof of Evidence (see 2/CGLP/5/4)
Witness 9: Mr Alan Simmonds (Planning & Policy)
1/CGLP/9/1 Proof of Evidence [340 KB]
1/CGLP/9/2 Appendices to Proof of Evidence [3,839 KB]
1/CGLP/9/3 Rebuttal Proof of Evidence in response to Mr Graeme Tulley with [33 KB]
Appendices in response to Mr Graeme Tulley [40 KB]
1/CGLP/9/4 Summary Proof of Evidence [388 KB]
1/CGLP/9/5 Maps and photographs relating to route of Park Hill Recreation Ground and development site, prepared by Hunt Dobson Stringer
1/CGLP/9/6 Summary Statement
1/CGLP/9/7 Reasons for refusing planning permission
1/CGLP/9/8 Retail Routes: Ground Floor

DOCUMENTS PRESENTED AT INQUIRIES

1/1 Statutory Notice of Public Inquiries into Planning Permission, Compulsory Purchase Order and Stopping-Up Order
1/2 Opening Statement of behalf of Arrowcroft & Frogmore [75 KB]
1/3 Opening Submission on behalf of the Local Planning Authority [24 KB]
1/4 Opening Statement for Croydon Gateway Limited Partnership (CGLP) [602 KB]
1/5 Drawing of proposed Area presented by Mr Murray Beynon
1/6 Note on the Croydon Plan & the Transitional Provisions presented by Mr Russell Harris on behalf of the London Borough of Croydon
1/7 Drawing Plaza Level of Croydon Gateway Arena Development presented by Mr Michael Aukett
1/8 Set of Croydon Arena drawings (15 June 2007) presented by Mr Michael Aukett
1/9 Drawings of boundary and layout of Park Place development in Croydon
1/10 Areas Reconciliation (20-9-07) presented by Mr Michael Aukett
1/11 Questions from Mr Ian Hunter to be answered by Ms Bridget Rosewell
1/12 Greenwich Retail Study 2001 – 2011
1/13 Letter dated 16 August 2007 from Mr Andrew Pepler (Donaldsons) to Mr Alan Simmonds (DP9)
1/14 National Affordable Housing Programme 2008 11, Prospectus
1/15 Mayor of London – The Draft Mayor’s Housing Strategy, September 2007-09-26
1/16 Greater London Authority Affordable Housing – Development Control Toolkit, Donaldsons, July 2007
1/17 Draft Section 106 Agreement; The Mayor & Burgesses of the London Borough of Croydon and Central Croydon Regeneration LLP, 28 August 2007
1/17A Revised Section 106 Agreement dated 28 September 2007 with highlighted revisions
1/17B Revised Section 106 Agreement dated 28 September 2007
1/17C Section 106 drawings relating to community use of the Arena
1/17D Revised Section 106 Agreement dated 18 October 2007
1/18 Questions from Dr Jean Gooding to be answered by Mr Graeme Tully
1/19 Extract from draft Section 106 Agreement: Part 16 – Open Space
1/20 Document relating to Open Space submitted by Mr Graeme Tulley
1/21 Scaled drawing of plan in Proof of Evidence including external areas by steps submitted by Mr Murray Beynon
1/22 Croydon Arena – Estimated Use of Entrances submitted by Mr Murray Beynon
1/23 Comparison of Food & Beverage Concessions between Croydon Arena & Hamburg Arena submitted by Mr Murray Beynon
1/24 Note of Mr Nick Bridges on desire line references in Proofs of Evidence
1/25 Note of Mr Nick Bridges on Status of Cumulative Schemes
1/26 List and location plan with AZ Croydon Street Atlas of Accurate Visual Representations submitted by Mr Nick Bridges
1/27 Extracts of Minutes of Meeting with Housing Association submitted by Mr George Venning
1/28 Report on Financial Viability of Affordable Housing at Croydon Gateway – Donaldsons, 19 July 2007
1/29 Extract of Appendix 1 to the Inspector’s Report – Croydon Replacement Unitary Development Plan Public Inquiry – March/April 2005